I was talking about those files that we send out to other banks as the originating depository fin. institution. Our agreements with originators do state they will follow US Laws, but not sure they have been told specifically to check the names against the OFAC listing. I do believe it would fall back to the bank, not the company we are originating for, if one went through that was ultimately on the OFAC listing.
No, we don't check every check that goes through, but we do check every customer as well as every wire and I think you need to have procedures for ACH as well.
Do what you can, with what you have, where you are.